"Ron Natalie" wrote in
:

I'll argue two things here. First, for TSO-91c ELT's the
instructions for the continued maintenance are spelled out
specifically in the manual, including how to change the batteries.
There's no requirement to do the G switch test (nor any overriding
need to do so). That only has to be done every 12 months.

Very true. More specifically, the ELT battery life limit has been
around for many decades. The G-switch test requirement is what, 10
years old?

However, even if such testing were required, I argue the the
owner-pilot is still authorized to return it to service. After I
replace my main aircraft battery you can be danged sure I'm going to
test it before returning the aircraft to service.

I think we all agree that you can clearly test the ELT (within the other
limits set forth as to when and how such testing should be done). I
would recommend it.

Unfortunately, my reading (and this is purely my reading, nothing I have
seen from the FAA) is that this testing does NOT replace the required
yearly test of the ELT. That, it would appear, must be done by an A&P
and or IA.

You're making requirements that don't exist in the regulations. As
for changing internal batteries in things not designed to be easily
accessible, that is covered by the initial phrase in 43xA.c
"Preventive maintenance is limited to the following work provided it
does not involve complex assembly operations."

Lots of the Part 43.13 regs have that "complex assembly" phrase. I have
never seen a definitive statement on what that means. To my mother it
should probably include changing batteries in a flashlight. But I
replace surface mount components on multilayer PCB's all the time.
Pulling the cover of my ELT (six screws) and one molex connector hardly
constitutes "complex" in my book.

I would love for the definition of complex assembly to be "assemblies
involving tools and techniques not familiar to the operator" - but
somehow that seems entirely too reasonable. Has anyone ever seen an FAA
definition?

-----------------------------------------------
James M. Knox
TriSoft ph 512-385-0316
1109-A Shady Lane fax 512-366-4331
Austin, Tx 78721
-----------------------------------------------